Timbercreek Asset Management Privacy Policy

April 2014

Introduction

This Privacy Policy (the "Policy") describes the practices of Timbercreek Asset Management Inc. (“Timbercreek”) in connection with the collection, use and disclosure of Personal Information (as defined below) by Timbercreek Communities. At Timbercreek, we are committed to protecting your privacy through practices that limit the collection, use and disclosure of Personal Information to what is necessary for the intended purpose, including in respect to lease applications, approvals and administering your residency. This Policy was created to inform you of our commitment to protecting your Personal Information and is based on the general principles in Schedule 1 of the federal Personal Information Protection and Electronic Documents Act..

Definition of Personal Information

Personal Information includes any information about an identifiable individual. Some examples of Personal Information which Timbercreek may collect from you are:

  • Name
  • Age
  • Gender
  • Home address
  • Phone number
  • Family status
  • Income
  • Driver’s License (or other forms of identification)
  • Employment details
  • Emergency contacts

Purpose for the collection and use of your Personal Information

Timbercreek collects Personal Information from individuals applying for a lease and its residents and guarantors under leases. Timbercreek uses the Personal Information in connection with the services requested and/or provided, including (i) determining your suitability for a lease and (ii) the ongoing administration of your lease and the obligations thereunder. Examples of the manner in which your Personal Information may be used include: disclosing such information to any co-resident or guarantor, confirming your income, sharing information with credit reporting or collection agencies, contacting persons identified in documents submitted to us, contacting you should matters relevant to your residency arise, contacting you regarding the administration of the lease or the residency and providing your information to utility companies and other third party providers of services to residents in connection with the provision of utilities and other services to your unit.

Timbercreek may also disclose your Personal Information as it may be necessary in connection with operating our business, including as part of a disposition of your building, an assignment of your lease agreement, obtaining financing and as required or permitted by applicable law. In all such circumstances Timbercreek shall require the recipient of your Personal Information to maintain it in confidence and only use it as permitted by law.

Consenting to our collection, use and disclosure of your Personal Information

The collection, use or disclosure of your Personal Information by Timbercreek requires your knowledge and consent. At certain times, your consent for the collection, use and disclosure of your Personal Information may be implied from the manner in which it is collected. For example, when you provide us with your Personal Information in connection with a lease, you have implicitly consented to Timbercreek collecting, utilizing and disclosing your Personal Information in a manner necessary to determine your suitability for, and administer, your lease as further described in the paragraph above. Your consent may also be expressly provided by you. If Timbercreek collects, uses or discloses Personal Information for purposes other than those described above, prior to the collection, use and/or disclosure of such Personal Information, unless required to be disclosed by law, you will be informed of, and your consent obtained prior to, Timbercreek’s collection, use and/or disclosure of that Personal Information. If we intend to use and/or disclose Personal Information that we previously collected for a new purpose which is not authorized under applicable laws, your consent will always be obtained before we use and/or disclose it for that new purpose.

There are certain situations defined by law where, Timbercreek may or may not be required to collect, use or disclose your Personal Information without your knowledge of or consent thereof. One example would be if Timbercreek must disclose your Personal Information in order to comply with a subpoena or court order.

You may always choose not to supply Timberceek with your Personal Information. However, if you choose not to supply us with your Personal Information, it may impact our ability to offer you services or respond to your needs.

Retention of your Personal Information

Timberceek will retain your Personal Information for as long as it is necessary to fulfill the purpose for which it was collected and to comply with applicable laws. After the Personal Information is no longer necessary either for the purpose for which it was collected or to comply with any laws it will be destroyed, erased, or made anonymous in accordance with Timbercreek’s document retention and destruction policies as in effect from time to time. You may revoke your consent to collect, use or disclose your Personal Information subject to applicable law and as may be required by Timbercreek in connection with any legal obligation previously entered into.

Protection of your Personal Information

Timbercreek will protect your Personal Information in a manner that is consistent with and appropriate to the sensitivity of that Personal Information. Our handling of your Personal Information will respect its confidential nature at all times from the time of its collection until its ultimate disposal or destruction.

Accessing your Personal Information

Access to your Personal Information held by Timbercreek may be requested by contacting the Director of Customer Experience in writing. We will respond to any access request within thirty days of receiving your request. Any questions with regard to requesting access to Personal Information may be addressed to the Director of Customer Experience. You are asked to provide us with any updates regarding any inaccurate or incomplete Personal Information.

Responsibility for compliance with our Privacy Policy

The President of Timbercreek Communities is responsible for overseeing Timbercreek’s compliance with this Policy and may be contacted at the following address - 1000 Yonge St., Toronto, Ontario, M4W 2K2.

Questions or concerns about our privacy practices

Please address any questions or concerns about our compliance with this Policy or our privacy practices generally to the Director of Resident Experience.